Google now confirms that that figure, in contrast to what Jobs implied, does not include upgrades. A spokesperson tells me it also factors in only devices that utilize Google services, meaning the total number of handsets in circulation is actually even higher.

Whoops -- sorry, Steve-O. You might have looked into that a bit more carefully before sounding the Apple alarm.

Even if you forgive his incorrect upgrade assumption, Jobs' assertion that Apple's "ahead of everyone" is pretty misleading. Jobs' 230,000-activations-a-day number covers all iOS devices, meaning it includes iPhones, iPads, and iPods. (But not iCarambas.) The Android sales figures focus solely on phones.

Talking about sales of smartphones powered by a particular platform and talking about combined sales of phones, MP3 players, and tablets are two very different things. Most independent mobile market analyses focus on the former; comparing apples to apples, so to speak, is the only way to have a consistent and meaningful comparison.

That distinction aside, it's been almost an entire month since Google mentioned the 200,000-Android-activations-a-day figure. Based on recent growth trends, it'd be surprising if that number weren't now higher.

Consider this: In February, Google said it was activating 60,000 Androids a day. In late May, the number was up to 100,000. One month later, in June, it had grown to 160,000. And then in August, it reached that aforementioned 200,000 milestone.

Since then, three out of four of Samsung's Galaxy S phones have hit the U.S. market. We saw the introduction of Motorola's Droid 2, the successor to the hottest-selling Android phone to date. And other popular Android devices continue to sell out as quickly as they're made. All put together, one would imagine the number of daily Android phone activations has well surpassed Apple's (nonphone-specific) 230,000 mark.

Of course, regardless of which platform is in first, second, or third place, what really counts as a consumer is which device you like. And obviously, numbers alone don't dictate financial success; Apple could be in fifth place and it'd still be turning a handsome profit. (A fiercely loyal fan base goes a long way.)